ARTICLE 11
INTEREST 1. Interest arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such interest may also be taxed in the Contracting State in which it arises and according to the laws of that State, but if the beneficial owner of the interest is a residen t of the other Contracting State, the tax so charged shall not exceed :
(a) 10 per cent of the gross amount of the interest if it is
received by any financial institution
(including an insurance company);
(b) 15 per cent of the gross amount of the interest in other cases.
3. Notwithstanding the provisions of paragraphs 1 and 2, interest arising in a Contracting State and paid in respect of a loan made by or guaranteed or insured by the Government of the other Contracting State shall be exempt from tax in the first-mentioned Contracting State.
For the purposes of this paragraph, the term "Government"
(a) in the case of Thailand, means the Government of
the Kingdom of Thailand and shall include :
(i) the Bank of Thailand ;
(ii) the Export-Import Bank of Thailand;
(iii) the Government Saving Bank;
(iv) the Government Housing Bank;
(v) the Bank for Agriculture and Agricultural Cooperatives;
(vi) any Ministry or Department thereof;
(vii) any body of corporate wholly owned by the
Government of the Kingdom of Thailand;
(viii) any local authority or statutory body; and
(ix) any institutions as may be agreed from time to
time between the competent authorities of the
Contracting States;
(b) in the case of Norway, means the Government of
the Kingdom of Norway and shall include:
(i) the Central Bank of Norway;
(ii) the Norwegian Government Petroleum Fund;
(iii) the National Insurance Fund;
(iv) the Norwegian Guarantee Institute for Export
Credits and A/S Eksportfinans but only insofar
as the loan or interest is guaranteed or insured
by the Government of Norway or its political
subdivisions or local authorities;
(v) any statutory body or any institution wholly owned
by the Government of Norway;
(vi) any local authority; and
(vii) any institutions as may be agreed from time to
time between the competent authorities of the
Contracting States.
4. The term "interest" as used in this Article means income, from debt-claims of every kind, whether or not secured by mortgage, and in particular, income from government securities and income from bonds or debentures, including premiums and prizes attaching to such securities, bonds or debentures, as well as income assimilated to income from money lent by the taxation laws of the Contracting State in which the income arises. Penalty charges for late payment shall not be regarded as interest for the purpose of this Article.
5. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the interest, being a resident of a Contracting State, carries on business in the other Contracting State in which the interest arises, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the debt-claim in respect of which the interest is paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply.
6. Interest shall be deemed to arise in a Contracting State when the payer is that State itself, a local authority or a resident of that State. Where, however, the person paying the interest, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the indebtedness on which the interest is paid was incurred, and such interest is borne by such permanent establishment or fixed base, then such interest shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. 7. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Convention. ARTICLE 12
ROYALTIES 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent of the gross amount of royalties if they
are made as a consideration for the use of, or the
right to use any copyright of literary, artistic or
scientific work;
(b) 10 per cent of the gross amount of royalties if they
are made as a consideration for the use of, or the
right to use industrial, commercial or scientific
equipment;
(c) 15 per cent of the gross amount of other royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such cases the provisions of Article 7 or Article 14, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a local authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Convention. ARTICLE 13
CAPITAL GAINS 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State. 2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such a fixed base, may be taxed in that other State. 3. Gains derived by an enterprise of a Contracting State from the alienation of ships, aircraft or containers (including trailers, barges, and related equipment for the transport of containers), operated in international traffic or movable property pertaining to the operation of such ships, aircraft or containers, shall be taxable only in that State.
4. Gains derived by an individual who is a resident of a Contracting State from the alienation of shares or other rights in a company which is a resident of the other Contracting State, as well as gains from the alienation of options or other financial instruments related to such shares or rights, may be taxed in that other State, but only if the alienator has been a resident of that other State at any time during the five years immediately preceding the alienation of the shares, rights, options or financial instruments.
5. Gains from the alienation of any property other than those referred to in the preceding paragraphs shall be taxable only in the Contracting State of which the alienator is a resident. ARTICLE 14
INDEPENDENT PERSONAL SERVICES 1. Income derived by an individual who is a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that State. However, such income may also be taxed in the other Contracting State if:
(a) the individual is present in the other State for a period
or periods exceeding in the aggregate 90 days within
any twelve-month period; or
(b) the individual has a fixed base regularly available to
him in that other State for the purpose of performing
his activities;
but only so much thereof as is attributable to services performed in that other State. 2. The term "professional services" includes especially independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, dentists, lawyers, engineers, architects and accountants. ARTICLE 15
DEPENDENT PERSONAL SERVICES 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if :
(a) the recipient is present in the other State for a period
or periods not exceeding in the aggregate 183 days
within any twelve-month period; and
(b) the remuneration is paid by, or on behalf of, an employer
who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent
establishment or a fixed base which the employer
has in the other State.
3. The provisions of paragraph 2 shall not apply to remuneration derived by a resident of a Contracting State, in this paragraph called "the employee" and paid by or on behalf of an employer who is a resident of that State in respect of an employment exercised in the other Contracting State where:
(a) the employee renders services in the course of that
employment to a person other than the employer who,
directly or indirectly, supervises, directs or controls the
manner in which those services are performed; and
(b) the employer is not responsible for carrying out the
purposes for which the services are performed.
4. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic, by an enterprise of a Contracting State may be taxed in that State. However, where remuneration is derived in respect of an employment exercised aboard a ship registered in the Norwegian International Ships' register (N.I.S), such remuneration shall be taxable only in the Contracting State of which the recipient is a resident.
5. Where a resident of a Contracting State derives remuneration in respect of an employment exercised aboard an aircraft operated in international traffic by the Scandinavian Airlines System (SAS) consortium, such remuneration shall be taxable in the Contracting State of which the recipient is a resident. | 
